THE BACKGROUND TO THE CASE STUDIES SELECTED
CHAPTER 5 CHAPTER 5 PROJECT ANALYSIS
5.5 The Investigation of Significant Issues
be followed and did not always enlighten I&APs about their right to influence the EIA process. The impression is gained that were it not for the ability of landowners to delay projects, Eskom could have circumvented the IEM procedure and the demands of I&APs as and when it wished.
Where there was strong potential for opposition Eskom made allowances and developed specific guidelines. The general trend, however, was not to open the procedure up for debate.
sites superficially investigated (De Kock, 1991). The feasibility study recommended that an EIA into 5 of these alternative sites and their associated lines be conducted.
The first Ariadne Venus 400kV line EIA, states: "The final option selected was for a substation integrated at 400kV, to be called Ariadne. This was after exhaustive environmental and topogaphical studies had been completed" (Eskom, 1993b, point 1.3). This shows the difference that existed between what the Eskom environmental officer perceived to be a feasibility study as opposed to other departments who perceived it to be an 'exhaustive' study. The Transmission Expansion Planning Report stated: "A detailed investigation led by Land Survey (not Eskom environmental management) showed that only two feasible sites (of the five) existed which met all criteria for suitablity" (Estment, 1994, p 9). Thus the feasibility study's recommendation of further investigating the 5 remaining sites was considered adequate and not subject to further review and scrutiny and formed the basis on which to make a final decision. No further investigation was allowed and the EIA was not concluded (De Kock, pers comm., 1997).
The Transmission Expansion Planning Report continued: "An on site inspection on 25 June 1992 showed that the southern site was the more suitable of the two sites" (Estment, 1994, p 9) i.e. the number of suitable sites was narrowed from 5 to 2. Although the reasoning mentioned in the report, such as consideration of the potential for violence, suggests cognisance of the issues identified in the feasibility study, predominantly electrical and economical reasons were given for the preferred selection of the site near Thornville.
The final statement in the report read: "The social impact assessment initiated .... must be concluded for the final site and transmission lines' route selection. It would be extremely dangerous to ignore these social issues" (De Kock, 1991, P 48). The social implications were therefore ignored. The construction of a new substation could have given the appearance that a particular politically alligned sector of the population was being favoured over a rival faction in terms of employment opportunites or electricity, and this could have halted the project or even exacerbated the violence already prevalent in the area.
Ariadne-Venus 400kV line
On the Ariadne-Venus 400kV line EIA (first attempt) only detailed investigation was undertaken on the Eskom prefered corridor by means of site visits, consultation with I&AP's and the use of specialists.
The latter request for this had been made subsequent to the EIA becoming controversial and a review thereof requested. This is therefore considered not part of the initial or first EIA. Reports on Oribi buck, birds, the veld and agricultural practices were obtained. This was subsequently found lacking on numerous counts and investigation intensified especially for the crane species in the study area during the repeat of the EIA. This study was continued post construction and was only finalised years later showing the limitations associated with investigations for project EIAs.
For the Ariadne-Venus 400kV line EIA (repeat) numerous biophysical, social and economic issues, in response to comments of I&APs, were investigated in an attempt to focus the current as well as future EIAs on only the more significant issues to be investigated.
As a result of this thorough EIA, the need for a study into the impact of Eskom powerlines on the three species of crane in the KZN Midlands was realised and extended into a five year national study funded by Eskom. Funding approximated R3 million (McCann, pers comm., 1998). Numerous beneficial innovations and procedures were developed to limit the impact of Eskom powerlines on birds nationwide as a result of this single study. This supports the use of detailed studies which can be applied to generic issues at a national scale.
It is obvious how little emphasis is placed on the need for adequate and detailed investigations. The use
of the Wattled Crane issue was exploited emotionally by I&APs as was to become evident in years to come (McCann, pers comm., 1998). This further supports the need to conduct adequate investigations and base decisions on a stronger scientific and more objective basis.
Hector-Klaarwater 275kV line
On the Hector-Klaarwater 275kV line EIA the only advancement and reduction in time on the thoroughness with which issues were investigated was that specialist consultants should have been appointed to deal with specific aspects of the environment (Clara, pers comm., 1999). Although the issues had been thoroughly investigated according to existing literature no specialists were consulted in this regard. There was an assumption therefore that the Eskom environmental officer was sufficiently capable of such a task, at the time, negating the need for specialist studies.
Ariadne-Hector 400kV line
On the Ariadne-Hector 400kV line EIA information gathered by Eskom was given to the consultant who elaborated on it. The only investigation or specialist study conducted within the study area was that on the geology and geotechnical conditions in order to ascertain design criteria for towers. Certain publications (literature) and experts were consulted on future development within the study area and the NPB was consulted on the biophysical component.
Hector 4001275kV substation
The lack of investigation associated with Hector substation due to time constraints was to result in extreme environmental degradation. Subsequent studies, post construction commencement, were to emphasize this oversight (Ward, 1996; Burger, 2000b).
Unlike Project Management who were unaware of the risk of undertaking construction without first considering the environmental consequences, Transmission Design were very aware of the environmental risks being taken (Ryan, pers comm., 1997). When Transmission Design began investigating the site they were in possession of an internal environmental brief entitled: "Substation:
Environmental Design Requirements" which alerted them to environmental impacts specific to substations (Visser, 1993). The Design Department objected to the project's lack of environmental input and endeavoured to make up for this neglect (Ryan, pers comm., 1997). They focused on three concerns or issues which they surmised were important, namely, time constraints, visual impact and soil erosion. Their awareness and willingness to consider environmental criteria when designing substations was heightened by the controversy surrounding the Ariadne-Venus 400kV line EIA. They investigated the environmental implications of using alternative technologies. The use of a Gas Insultaed Substation (GIS) was compared to an Air Insulataed Substation (AIS). The GIS was considered as it has the advantages of being physically smaller, possesses higher reliability and requires less frequent maintenance than conventional outdoor switchgear. The smaller physical size results in a much smaller substation site being required and less visual and physical impact on the environment. Less extensive earthworks would have thus been required at the Hector site and it would not have been necessary to deviate the existing 88kV lines (Estment, 1994). But this comparison of alternative technologies was to be of little avail when the costs of a GIS were deemed prohibitive by Eskom management.
The consultant appointed an archaeologist and an ornithologist. An archaeological survey of the site revealed no artefacts of significance. A preliminary report by the ornithologist on the rare Blackrumped Buttonquail concluded that: " .. any measures which minimise the loss of grassland will be of value, .... The best mitigatory measure would be a 2-3 year study by a full-time researcher ... "
(Berutti, 1994, p 69). This request was dismissed by Eskom but should have at least ensured that the loss of grassland be minimised.
A synopsis of the Head of NPB's Biodiversity Department's comment on the draft EIR, is quoted below and clearly expresses disdain for the lack of investigation of environmental issues:
"In the Executive Summary it is stated that it was the purpose of the report to study the impacts of the proposed substation on the environment. To achieve this purpose, a comprehensive ecological evaluation of the site is necessary. Our general comment on the report is that there are significant errors of fact and interpretation in the ecological analysis of the site. This generalised and flawed overview of the site does not assist in anticipating potential negative impacts of the proposed development and subsequent mitigation recommendations" (McCI intock, letter, 1994c).
The EIS ended with the emphasis on the inadequacy of the studies:
"Incomplete or Unavailable Information - It must be reiterated that this study is of a pioneering nature. Very little research exists on the impacts of substations on the natural environment. Public participation only very recently became part of environmental management. Therefore even knowledge about perceived impacts is inadequate. ... It was not considered necessary to appoint specialists to study plants and fauna as the existence of rare/endangered species is small. Continued monitoring by substation staff is advisable" (Gouws, et ai, 1995a, p 59).
The environmental consultant for Hector EIS attempted to justify the lack of the appointment of specialists by reasoning that: "... time was extremely limited. This limited to a certain extent the number of specialists we could involve in the project. Eskom is doing far more than many other companies for the environment and certainly more than required by law at the moment. It is therefore not the place of the consultant to spend the client's money without proper motivation" (Gouws, et ai, letter, 1994b). It is valid that the appointment of specialists was indeed constrained by time, however, it remains the responsibility of the environmental consultant to recommend their appointment
dependent on the sensitivity of the receiving environment, irrespective of time constraints. Eskom environmental policy did not promote the position of undertaking minimal investigation.
The argument to not appoint specialists in order to curtail 'unnecessary' costs to the client is also considered circumspect. The EIA for the Ariadne-Venus 400kV line cost a minimum of R2 028 387. This figure is considered incorrect by the environmental officer concerned with the Ariadne-Venus 400kV line second ElA, as it excluded numerous environmental costs placed in other accounts and a more accurate estimate was approximately R4 194 000 on a project which cost R94 012 755 (Willemse, pers comm., 1997). The Ariadne-Hector 400kV line ElA, which was alligned with IEM standards, amounted to R455 674 on a R54 920 602 project. Even the extreme significance of Hector substation which was to supply about 6 million (roughly 15 % of South Africa's then total population) warranted the additional expense. Similarly savings on early development, since the project was brought forward by a year, gained Eskom R37,79 million in revenue (Eskom, 1995b). The inconsistency of expenditure is not justifiable when compared with the amount spent on project's of lower cost. Only R40 000 was allocated for the environmental consultant's appointment at Hector substation (this excludes any fees for the two specialists appointed) on a project initially estimated at costing a total of Rl19 635 999. This shows that Eskom was being extremely frugal when spending on environmental investigation at Hector. The money spent on the further rehabilitation and control of soil erosion in the year 2000 exceeded RI 000 000 including survey, subsequent research post construction and the installation of gab ions to partially repair and contain damage. A substantial amount of money could therefore have justifiably been spent on research and preventative measures rather than trying to fix damage after the fact. It is also difficult to attach a cost to environmental damage such as soil erosion and the species loss which transpired. The cost of the loss of 7 897m3 soil and siltation downstream is difficult to estimate as it cannot be replaced and the financial implications due to damaging the ecosystem cannot be measured.
Key issues that were identified in the EIS were the visual intrusion, destruction of grassland habitat, threat to the endangered Black-rump Buttonquail, due to loss of habitat, erosion of soils and the nuisance value of construction activities to residents. In spite of recommendations to investigate further the endangered Black-rump Buttonquail only investigations into the botanical composition of the site were to be undertaken at the request of the NPB. This transpired only subsequent to the review of the draft EIR after construction had commenced on 19/12/95.
What was thought to be a degraded Aristida junciformis grassland (sour grassveld of low significance and value) from superficial examination (Gouws, et aI, letter, 1994b) was to reveal a botanically significant site worthy of conservation - 650 plant species have been recorded to date (Ward, pers comm., 1997).
The botanical report emphasised the following:
• the central drainage (which came to be known as the 'kloofie') and its slopes should be conserved, not only for the sake of the good examples of trees and other interesting plants (such as one of the taller Hibiscus fuscus recorded for this region) lining the watercourse, but also for the stabilising influence this has on the slopes below the current earthworks;
• the grass lands around the substation should be conserved as an asset to science and education in general; and
• final discharge of stormwater from the site after construction should be such that it will not damage existing vegetation downslope. This would cause the loss of individual plants, some of which may be of scientific value, and most importantly, it would initiate gulley erosion leading to costly remedial measures being implemented in the future
(Ward, 1995).
These findings were presented too late to have any significant bearing on the project and all of these negative predictions have materialised.
The use of a tubular busbar AIS instead of the steel lattice busbar AIS lowered the substation height from 25m to 10m and has succeeded in making it far less conspicuous against the backdrop of the hillside on which it is situated. This significantly decreases its aesthetic impact, especially from the N3 national road from where it is now hardly visible. This mitigation measure, however, was as a consequence of the Eskom Design Department's initiative and not as a result of the EIS undertaken by the environmental consultant. In spite of Eskom Design adequately lowering the substation and mitigating its visual impact there still remained an inordinate emphasis on the aesthetics of the substation by the environmental consultant. This, it is surmised, may be attributted to her background as a landscape architect. She continued to emphasise the need to plant trees to conceal the substation oblivious to the fact that the receiving habitat was a grassland and it would be immensely difficulty to establish and maintain trees by Eskom maintenance due to watering costs, depth of soil immediately below the substation, fire prevention, etc. The botanist's comment contradicted this recommendation
as the area was a natural grassland unsuitable for planting trees. Trees (funded by a grant from Holland) subsequently planted have all been destroyed by fire.
The consultant's opinion of the site and the investigation of issues was based solely on the following statement and a single site visit by NPB personnel: "Screening was done with the help of the Parks Board: ... Apart from the Black-Rumped Buttonquail, they both said that there was nothing specifically sensitive about the site" (Gouws, et ai, letter, 1994b). This was refuted by an NPB Planner who stated: "I have made some enquiries regarding the preliminary discussions on the Hector substation, and wish to confirm that at no stage during the scoping exercise conducted with the consultant was it stated by Board staff that an ecologist was not required for the baseline study. It was stated that the site was degraded, but that there were biological components which required further ecological assessment" (Sandwith, letter, 1995).
Another of the Natal Parks Board's comments was: " ... the Board needed to assess whether proposed mitigation or restitution measures would adequately protect nature conservation interests relative to the project. To make these assessments, the Board required data of a sufficient standard and accuracy which, unfortunately, were not forthcoming in the study" and "The shortcomings of the assessment are many, and perhaps the greatest concern is that it does not provide a firm basis for assessing the significance of impacts or determining recommendations which would result in a successful development. Eskom has the opportunity to develop a model substation on this particular site if all possible mitigation, construction and post-construction management measures were documented and implemented" (McClintock, letter, 1994c). Thus the investigation was considered by the NPB, a highly reputable body of scientists, to be inadequate.
The consultant used the excuse that "no long term studies exist of the fauna and flora of the area"
(Gouws, et aI, 1995a, p 59). The onus, however, rests with Eskom and its consultant to undertake the necessary studies where none previously existed.
Upon completion of the terrace cut, vast portions of the banks were washed away on two occasions, associated with the high rainfall experienced during March 1996 resulting in large-scale deposition on the slopes of the central drainage and shallow slopes below the substation -an area approximating 10 000m2 in extent. This included the inundation of the wetland below. After the heavy rains during July 1996, Umgeni Water, complained about the volume of water that emanates from the substation platform. After the heavy rains in July (127,5mm for the month), the underscouring of Reno
mattresses began at one point along the pipeline below the Eskom property. Umgeni Water expressed concern that runoff from the substation platform area could damage the pipeline (Van der Kooy, 1996a). Runoff eventually caused the pipeline to break in 1999 (Burger, 2000b).
The removal of vegetation and hardening of a large portion of the catchment surface due the substation's construction, irreversibly altered its runoff regime. Five pipes discharge water immediately below the substation terrace. This water is collected from the platform as well as a portion of the high cut-bank behind the substation - an area totalling approximately 22 ha in size. In order to prevent the myriad of gullies which had begun to form throughout the veld, the discharge from the 5 outlets was canalised to one point at the top of the central drainage line, referred to as the kloofie. The EIS stated that this region receives some of the highest rainfall in the country. The average number of days that rain could be expected in a year is 73 days spread through every month of the year, with +- 71 % in the summer period from September to March. However, this general information is of little benefit to design engineers. Subsequent interrogation and easy interpretation of records revealed more pertinent information. Beckedahl (1998, cited in Burger, 2000b) stated that climate records for the area show that high intensity rainfall is not uncommon, with on average at least one storm per annum with intensities of more than 50mm per hour lasting in excess of one hour, and storms of 80mm per hour intensity on average once every 2.3 years. Burger (2000b) measured run-off for four storm events between 1997 and 1999. Run-off readings were highly variable but ranged from an estimated 2.4 lis to 3631 lis. Other readings are noted in Table 9 below.
The Hector EIS report neglected to adequately estimate the volumes of run-off to be associated with the rainfall events once the substation was constructed and thus failed to recommend adequate and very costly but necessary mitigatory measures. It merely stated that "stormwater management should be an important factor in this study, and if the stormwater is managed properly, it will prevent land and watercourse erosion, ... " (Gouws, et aI, 1995a, p 23). It also did not indicate that this would result in the impact of erosion beyond the substation's immediate boundaries and its potential to seriously erode neighbouring property.
The erosion processes evident were also previously confirmed by Brink (1981, cited in Burger, 2000b) who noted that slope stability problems are common in the area - associated with the residual soils and weathered rock materials. The soil material effectively "liquefies" when saturated, to cause failure.
Miss S Rienks in consultation with Prof. Hughes, Department of Agriculture, University of Natal, Pietermaritzburg and Mr V Roberts, Soil Scientist, Department of Agriculture, Cedara, both verified